Calgary (City) v. Canada, [2012] 1 S.C.R. 689, 2012 SCC 20 -- summary under Section 24

By services, 28 November, 2015

The City of Calgary unsuccessfully submitted that its activities of acquiring public transit asset and making them available for use in its transit system constituted a separate taxable supply made to the Province of Alberta (which provided funding therefor) rather than being part of its making of exempt municipal transit services to the public. Furthermore, even if the Province could be regarded as being a second recipient (in addition to the Calgary public) of the municipal transit services made by the City, this did not detract from this supply being included as an exempt supply in Schedule V, Part VI, s. 24, as this provision "does not indicate that the supply must be made exclusively to members of the public" (para. 65).

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